Free Motion to Compel - District Court of California - California

Case 3:07-cr-03056-WQH

Document 12

Filed 12/03/2007

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FREDERICK M. CARROLL California State Bar No. 227628 424 F Street, Suite A San Diego, CA 92101 Telephone: 619-702-3251 Attorney for Ms. Bierly

5 6 UNITED STATES DISTRICT COURT 7 SOUTHERN DISTRICT OF CALIFORNIA 8 (HONORABLE WILLIAM Q. HAYES) 9 UNITED STATES OF AMERICA, 10 Plaintiff, 11 v. 12 ELOISE BIERLY, 13 Defendant. 14 15 16 TO: 17 18 PLEASE TAKE NOTICE that on December 17, 2007, at 2:00 p.m., or as soon 19 thereafter as counsel may be heard, the defendant, Eloise Bierly, by and through her counsel, 20 Frederick M. Carroll, will ask this Court to enter an order granting the following motions. 21 MOTIONS 22 The defendant, Eloise Bierly, by and through her attorney, Frederick M. Carroll, 23 pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all 24 other applicable statutes, case law and local rules, hereby moves this Court for an order: 25 26 27 28 1) compelling discovery; and, 2) granting leave to file further motions. KAREN P. HEWITT, UNITED STATES ATTORNEY, AND PAUL COOK, ASSISTANT UNITED STATES ATTORNEY: ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 07CR3056-WQH DATE: TIME: DECEMBER 17, 2007 2:00 p.m.

NOTICE OF MOTIONS AND MOTIONS: (1) (2) COMPEL DISCOVERY; AND FOR LEAVE TO FILE FURTHER MOTIONS ________________________________

Case 3:07-cr-03056-WQH

Document 12

Filed 12/03/2007

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These motions are based upon the instant motions and notice of motions, the attached statement of facts and memorandum of points and authorities, and all other materials that may come to this Court's attention at the time of the hearing on these motion.

Respectfully submitted, /s/ Frederick M. Carroll Dated: December 3, 2007 Frederick M. Carroll Attorney for Ms. Bierly

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07CR3056-WQH